The Spacial Strategy proposed here is utterly unsound for multiple reasons.

Firstly, about 5% of the Borough of Brentwood is South of the A127, yet the council proposed to build 4080 houses there (3500 in Dunton Hills Garden Village and 580 in West Horndon) This is more than 50% of the assessed need for housing.

The area South of the A127 is not well connected to the rest of the Borough due to the poor road connections via Ingrave, Herongate and Warley.

Development South of the A127 will not be effective in meeting the housing needs for the rest of the borough which will be undersupplied with affordable and specialised housing.

Development South of the A127 will do little of alleviate the high cost of housing in central and Northern Brentwood.

Brentwood Council accepts a need for 7,600 homes throughout the borough. Basildon has a need for about 20,000 and Thurrock a need for 32,000 which will be accomodated therein. It is therefore unhelpful of Brentwood to add to the development close to Basildon and Thurrock instead of meeting its own needs further North.

Central government has invested billions of pounds in transport infrastructure along the A12 corridor including Crossrail and the widening of the A12. This would not have been done if it was not expected to increase transport capacity around Brentwood. They will rightly expect this to unlock housing development along this corridor, not the A127 corridor as proposed in this spacial strategy. The few thousand home proposed along the A12 corridor is insufficient to meet this expectation.

Brentwood Council may argue that concentrating development in a new garden village will make it easier to raise funding for infrastructure. However, the A127 is already known to have been heavily underfunded since it was detrunked in 1997. It is of a low standard for the existing traffic and will suffer from further increases. No funding has been proposed on a the scale necessary to mitigate the load from further development, and even if funding were arranged improvements could not be implemented in the timescale of development for the current local plan.

This continues to represent a reasonable approach and I support it, as I did for the Draft Local Plan (2016).

We are putting forward representations in respect of a proposed village extension at Mountnessing.
The site is in a sustainable location, served by existing and proposed services and facilities.
Please see documents as attached in respect of the Strategic Objectives

Earlier stages of the local plan process involving consultation and accompanying assessments - contained most particularly in relevant Sustainability Appraisals have presented a logical narrative to the spatial strategy contained in the current Regulation 18 consultation document. As detailed in paragraph 6.3.2 of the Sustainability Appraisal Interim Report January 2018, the option of developing a new community between West Horndon and Basildon has featured in the appraisal of reasonable spatial strategy alternatives within the 2015 and 2016 Interim SA Reports. In our view, the draft spatial strategy is properly set to achieve the Vision and Strategic Objectives of the Plan and has properly considered the various other options for growth. In the case of the contribution to be made by DHGV the Promoters have confidence in being able to deliver the form, scale and timing of development required to make its contribution towards achieving the Spatial Strategy

Housing -
ECC acknowledges BBC's work that seeks to meet housing needs in full over the Plan period (7,600/380 dpa) and supports the 20 year Plan period (2013 - 2033). This would deliver the BBC's housing need in full and support the projected number of jobs/workers forecast in the Plan period. ECC supports the prioritisation of bringing forward brownfield sites and all appropriate land within existing urban areas, and through maximising density where appropriate. This will direct development towards existing settlements, particularly those that already benefit from access to a range of services and access to sustainable transport modes. However, in doing so any strategy will need to demonstrate that the level of growth can be accommodated by the existing and new social and physical infrastructure.

ECC acknowledges that BBC will need to be satisfied that the Local Plan is supported by a proportionate evidence base and that all reasonable alternatives have been considered. See ECC earlier commentary on the SA.

Following its response to the 2016 consultation, ECC continues to seek further clarification on a number of issues in relation to the proposed spatial strategy including:
* how the A127 Corridor provides more opportunities for growth than the A12 Corridor;
* identification of any cross border implications of the spatial strategy given its role as highway, education, minerals and waste, and lead local flood authority, and public health responsibilities;
* identification of what infrastructure is necessary to deliver the spatial strategy, strategic and individual site allocations; and
* a full assessment of the highway and transportation implications of the proposed spatial strategy, both in terms of the impacts of the individual preferred site allocations, and cumulatively.

ECC therefore withholds support until the appropriate highway modelling has been undertaken, to assess both the site specific and cumulative impacts of such developments on the local, and wider highway network.

Transport and Highways -
BBC commissioned PBA to assess the impact of options for strategic development within the Borough in the coming years. The `Brentwood Borough Local Plan Development Options - Highway Modelling' was published in draft form as part of the 2016 consultation. The draft Report set out the approach of PBA to highway modelling, the results of the modelling and junction assessments, and highlighted those worse performing junctions that may require mitigation, to enable the development sites to come forward.

4.38 ECC reviewed PBA's draft Report in 2016, and provided a significant number of comments and concerns to BBC. ECC highlighted that there were still areas of the methodology that would benefit from further clarification, and aspects of the modelling that would need to be revisited.

4.39 ECC highlighted that any further modelling work would need to consider a number of matters including:
* Rebuilding of forecast matrices to account for revisions made to development numbers contained in the Local Plan,
* Recalculation of trip rates to also account for sustainable travel,
* Consideration of background growth to incorporate fuel efficiency and income growth factors,
* Validation of base model outputs to observed conditions,
* Sensitivity testing of forecast model assignment,
* Determining how the model can be improved to provide a more accurate assessment of cross-boundary impacts,
* Remodelling of all junctions currently in scope of assessment, accounting for uneven lane usage, peak hour demand profiles and the impact of pedestrian movements.

4.40 ECC also advised that no analytical work had been undertaken on the strategic route network (A12 and M25) or in relation to the A127, which given the level of growth required, raised concerns.

4.41 The A127 is a vitally important primary route for the South Essex area which connects the M25, Brentwood, Basildon and Southend (including London Southend Airport). A major aim of ECC is to improve journey time reliability along this route. There is significant growth planned along the A127 corridor in adopted and emerging Local Development Plans along its entire route, which will need to be considered in any highway modelling in terms of capacity, key junctions and access.

4.42 The impacts of the preferred route of the LTC will need to be assessed and factored in to the further modelling in support of the Draft Plan. It is considered that the LTC would have an impact on/ and opportunities for the Brentwood Borough as well as the wider transport network across South Essex and beyond. A new LTC will fundamentally change the dynamic of strategic transport movements within and across Brentwood and Greater Essex.

4.43 ECC is clear that the further modelling work needs to clearly illustrate the local and cumulative impact on the local and strategic transport network, to demonstrate that the proposed spatial strategy is the most appropriate, and to identify any mitigation measures which would be required. Any mitigation required will need to be clearly stated in the relevant policies.

4.44 ECC, as the Highway Authority, needs to be engaged on the further modelling work, to be satisfied with the approach, assumptions and outcomes, in order to provide support to BBC in the plan preparation process and at examination. As previously requested ECC require BBC to incorporate a review process, at the end of each stage, into the modelling programme.

4.45 BBC has begun work to address the outstanding issues and ECC are engaging with BBC and PBA to progress this. However, until this appropriate highway modelling has been undertaken, and ECC has reviewed and confirmed satisfaction of the work, ECC continues to withhold support for the Draft Plan.

Employment -
ECC acknowledges the ambition to develop new key strategic employment sites but this needs to be set within the wider context of Brentwood's Spatial Strategy, and any location to be consistent with the criteria to seek to ensure future developments are located in accessible locations reducing the need to travel. ECC therefore withholds support until the appropriate highway modelling has been undertaken, to assess both the site specific and cumulative impacts of such developments on the local, and wider, highway network.

ECC raises concerns over the allocation of 57% of the new employment land on one site, Brentwood Enterprise Park (BEP). The Economic Forecast Report also highlights concerns with regard to the considerable reliance on the BEP employment allocation. It is recommended that consideration be given to the phasing and deliverability of the site, to ensure a readily available supply of employment land across the short, medium and long term.

Furthermore ECC would draw attention to the 'red line' boundary for the LTC major road scheme, which seeks to incorporate a significant part of the BEP employment allocation. Whilst it is acknowledged that one of the aims of the LTC is to be a key driver for economic activity, and if such a scheme is not to impact on the deliverability of the BEP, clarification is sought over this matter, and in respect of the deliverability of the full allocation over the Plan period, particularly given the need for the site to come forward in phases over the short, medium and long term.

ECC acknowledges the significant contribution the BEP allocation would make to meeting the employment needs of the Borough over the Plan period. However, its location, in close proximity to the M25 and A127, which is presently over capacity, provides primarily car based connections to service centres, and potential sources of employees. The location is not favourable to sustainable transport measures and at present there is limited evidence regarding any potential connectivity of the proposed development via sustainable transport measures. Additional clarification will be required regarding opportunities for such measures, and the output of any impact on the strategic junction, local road network and potential mitigation requirements to be programmed (as part of the IDP). The potential impact on the above would also depend on the mix of B1, B2 and B8 uses proposed on the site.

Infrastructure -
ECC agrees that the Local Plan will be critical for making sure BBC has the right infrastructure, at the right time, to accommodate the new jobs and homes proposed within the Plan period. ECC considers that large scale housing developments will need to include appropriate infrastructure such as education provision, community and health facilities, flood mitigation through SUDs, and improvements to transport infrastructure. Small scale development should also fund improvements to existing services and facilities. ECC note that infrastructure provision is likely to have a major impact on the phasing and deliverability of development.

ECC consider the phasing of development and funding of infrastructure will be crucial for effective delivery and this will need to be reflected in the evidence base as Local Plan preparation progresses. Currently ECC consider that this is unclear.

ECC therefore consider it essential that all sites are assessed together as part of Plan preparation to identify which sites or strategic locations are the most suitable and deliverable for a particular use. It is imperative that the costs of providing infrastructure as a direct result of development proposals, particularly those related to early years and childcare, primary and secondary schools, and highways, for which ECC has a statutory responsibility, are included in the viability assessment from the outset, to ensure provision is guaranteed. ECC seeks clarity on how this process has been undertaken.

ECC would draw BBC's attention to the ECC Full Council Motion in October 2014, reaffirmed in July 2017, which states that 'Essex County Council will not support Local (Development) Plans unless adequate resources are identified from developers, local councils and/or Government grants to ensure that sufficient infrastructure, including roads, schools, medical facilities, parking, sewerage and drainage, is provided in a timely manner and in a way that balances the needs to promote economic growth and provide housing for residents whilst protecting their quality of life'. In accordance with this Motion, it is recommended that ECC continues to withhold support for the Draft Plan, until the appropriate work in relation to ensuring the provision of all suitable infrastructure has been undertaken, and ECC has reviewed and confirmed its satisfaction with the work.

The Local Plan spatial strategy is of particular importance to ECC as it will need to be satisfied that the impact of any planned scale and distribution of growth can be accommodated by ECC areas of responsibility, or identify what additional facilities or mitigation are required to make the strategy sustainable in social, economic and environmental terms.

An IDP will need to be prepared to support the Local Plan, and identify infrastructure required. The Local Plan should make clear, for at least the first five years, what infrastructure is required, who is going to fund and provide it, and how it relates to the anticipated rate and phasing of development. For the later stages of the Plan period less detail may be provided as the position regarding the provision of infrastructure is likely to be less certain. As a provider of key services and subject to statutory responsibilities, for example minerals and waste; highways, education, early years and childcare; and public health, ECC is keen to assist BBC in the preparation of the IDP, and welcomes the opportunity for engagement with BBC to assist in the preparation of the Local Plan towards pre-submission. However, as stated above, until this appropriate work has been undertaken, and ECC has reviewed and confirmed its satisfaction with the work, it is recommended that ECC continues to withhold support for the Draft Plan.

Metropolitan Green Belt -
ECC is committed to working closely with its local authorities to meet the increasing demand for housing and infrastructure that meets the needs of residents, drives economic prosperity and protects and enhances the local environment. Paragraph 83 - 85 of the NPPF identifies that Local Planning Authorities should establish Green Belt boundaries that ensure consistency with the Local Plan strategy for meeting identified housing requirements in sustainable locations, and any Green Belt review should be undertaken as part of the Local Plan preparation.

The Draft Plan Spatial Strategy seeks to maximise development on brownfield sites within existing urban areas, including the redevelopment/allocation of employment sites for residential use. The commentary provided in the consultation document states that given the finite availability of these sites in the Brentwood/Shenfield urban area, and lack of such sites to meet the objectively assessed need, significant growth will be (required on green belt sites.

The Draft Local Plan contains two 'strategic objectives' (SO15 and SO16), which seek to safeguard the Green Belt from inappropriate development and to protect and enhance valuable landscapes, and the natural/historic environment. The Borough is covered by 89% Green Belt, along with a wide range of other environmental constraints including distinct landscape types of relatively high sensitivity to change; and two large Country Parks at Thorndon Park and Weald Park. Other designations include SSSI's, Local Nature Reserves, biodiversity habitats, and Thames Chase Community Forest.

ECC acknowledges the sensitive nature of the Borough and the need to balance growth with retaining local character. The Borough Council will need to be satisfied that it has identified its preferred spatial strategy, which includes significant Green Belt release, based on a range of proportionate evidence. In so doing, BBC will need to demonstrate that it has considered all reasonable locations for future growth against the relevant criteria, and demonstrate that the most appropriate sites have been identified for allocation.

Spatial Strategy General -
ECC welcomes reference in Paragraph 37 of the consultation document to BBC working jointly with the South Essex LPA's to secure infrastructure investment and consider wider growth opportunities. ECC recommends that more detailed reference is made to this work, including the Memorandum of Understanding that has been signed by the South Essex Authorities to work together on strategic cross boundary matters, the establishment of the Association of South Essex Local Authorities (ASELA), the work that has taken place on a South Essex 2050 Vision, and the work underway to progress a South Essex Joint Spatial Plan.

The draft plan refers to the accompanying sustainability appraisal, which is part of this consultation, but does not appear to be within the listed documents on the website link. Even so, Hermes Investment Management broadly supports the Council's spatial strategy insofar as it relates to the redevelopment of the sites making up the West Horndon Industrial Estate and the new employment allocation on land south of East Horndon Hall.

Thank you and refer to your letter of the 2nd February. In response please note that I object to these proposals because of the following: The infrastructure in Brentwood and the surrounding villages can simply not cope with the additional number of people and vehicles that the proposed development will create. The road system in, around and through Brentwood is already under extreme pressure during the school and working rush hour. Our schools are at capacity and over-crowded and our NHS / doctor services are exposed and not able to cope with the number of patients they already have. The majority of planned development is to be built on greenbelt land, which I do not consider to be necessary. The greenbelt is there to protect us and to support the environment. We can not afford to lose this for the sake of expensive housing only to make developers rich! Once gone it is irreversible. The planned housing is not aimed at first time buyers but will end up being marketed as 'executive housing' and out of reach by all but the very wealthy. The disruption the planned building will have for many years in and around Brentwood does not bear thinking about. As already mentioned the road system can not cope as it stands. The additional construction traffic will only add to the problem. It will also create an unacceptable level of pollution from both the construction and then, once built, the additional environmental effect the additional housing and vehicles will generate. This is particularly relevant to the vast Dunton Garden Village site which will back on to the A127 and A128 junction, never mind the additional traffic that is going to head that way once the new Thames crossing is build. The developers always under estimate and the planning committees always accept that there will be less cars allocated to each property. In the relatively recent development of apartments that was built at the entrance to the village of West Horndon the cars now park on the road causing a danger to other road users and pedestrians. I fear the same will be replicated in all future developments planned which will lead to further snarling up of our road system. A high proportion of people living in and around Brentwood work and commute into London on a daily basis. The C2C trains running into London from West Horndon are already over-crowded and unable to cope with the number of passengers they have. Adding thousands of new commuters to the line, even if a new station were to be built, simply doesn't add up. The infrastructure simply can't cope. Brentwood is a pleasant place in which to live. I have lived here all my life and chose to remain when raising my family. I fear that the proposed developments will cause huge harm to the town and on a wider scale to the environment. The infrastructure we have will not cope and it will, as a result, become a place that I, and I fear many others, will have to leave. Please accept this as my formal objection to the planning proposals BBC have set out in their Brentwood Development Plan.

100? or more new houses in Blackmore, that would mean 100 + families,100 or more cars.
We have had houses recently sold that have been extended, thus adding to the population.
Our school is full & cannot take any more children, the doctors surgery is working at full capacity. Even our post office has been reduced to a corner of the local shop.
This used to be a typical Essex village but will become a nothing place.
We will lose our green fields & gain nothing.
Let's call a halt to all this "development" before it is too late.
All this building has to stop somewhere otherwise we will have wall to wall concrete and no greenery anywhere. I, for one would not like to see that happen.

I Object to these plans because of the destruction of green belt land as well as additional congestion and pollution this will cause and the additional pressure on the public services. There would also be large destruction to the local wildlife.

I object to these proposals because of the planned use of green belt. Green belt should be preserved for our children and future generations to come.

I object to these proposals because it will destroy our greenbelt land. The increase in people living in the area will strain our already overloaded hospitals, schools etc. The road infrastucure is not sufficient for the extra households, which are already incredibly congested, and the extra houses and traffic as a result will cause in increase in pollution and destroy the areas for our natural wildlife.

I am writing to you this evening to express my strong feelings against more houses being placed in the area. Already, there is too large of a community for such a small area and having more people thrust into the mix is not going to help at all. To give an example, getting the train from Brentwood into London at rush hour is nearly impossible given that the trains only run every 30 minutes from Ingatestone. Getting on a train packed full of people is hard enough without a new population being added in. Additionally, I strongly advise you to think about the detrimental effects new developments will have on the environment. For every person added, there is a new amount of carbon emissions and deforestation which takes place and, being that Essex was once a farming community, I find it extremely disheartening that gentrification is taking us away from that once proud part of our shared identity. Please consider my views and I look forward to hearing any relevant response.

Having looked at the new development considered for Brentwood, I must register my complete disapproval of the intended plans for Brentwood. The changes proposed show a fundamental change in the very fabric of Brentwood and will see a more crowded, busier, nondescript environment for residents and visitors. Having lived in Brentwood for 30 years I have seen Brentwood turn from a town in itself to a mere commuting dormitory town. The moves cited will lead to more over population that the infrastructure of the town cannot support and I include both public transport and private travel in this. I would ask those who can make the decision take a long look at what is intended as once damaged there is little chance that these mistakes can be remedied.

(Housing sites and Larger villages): 1. There are already 5 houses in the village that have been left unoccupied for 5 years and over, as well as buildings with planning consent for conversion to 3 homes on which no action is being taken. New building is not needed while the existing stock is underused. 2. The mains drainage of the proposed central village location is unable to take such a large development. 3. Medical services cannot service the implied increase of 300-400 population. 4. The primary school is already full. 5. If the developments access Red Rose Lane, the ability to walk safely there will be lost; if they access the village centre through the existing estates, the central area will become even more dangerous to pedestrians. Much of the village has only limited pavements, and the ability of residents to walk safely is a fundamental right. 6. Wifi response speed is already very poor, due to the distance from the main hub in Brentwood [4.33 Mbps download, 0.35 Mbps upload at the time of writing]. A significant increase in users will make it even worse.

Further to reviewing the Draft document, I believe the key issue is maintaining the status quo for the current residents, each proposed development should have some benefit to the area and just a benefit to the developer??

I object to these proposals because we need to leave out greenbelt land alone, there are too many cars on the road, with no extra infrastructure. I'm queuing every morning to get myself to work & at 7.20 am Thursday morning cars were queuing back passed the Toomeys roundabout to get to the A127. It can only get worse unless resource is place on the roads in order to cope! The hospital is over run & there is no thought to how this extra resource will effect them. There are already too many cars on the road, with no extra infrastructure, just more pollution to this area.

(Priest Land, Brentwood; and Brentwood Town Centre generally): These sites should be excluded from the Local Development Plan (LDP) for the following reasons: Priests Lane and the surrounding roads are already congested and adding 90+ houses will increase traffic movements in peak hours by probably double the number of houses built. Access to the site from Priests Lane or St Andrews Place will create danger to cars and pedestrians. Priests Lane has a narrow pavement and additional hoses with children walking to school in Brentwood Town Centre may cause danger to the children. Pollution levels will increase in the area where levels already exceed EU limits. The road infrastructure, doctors. dentists and schools in the area cannot cope now and no provision has been made to improve these, Brentwood town centre is already at crisis point with traffic volumes and parking facilities unable to cope and any further building in or near the centre will only make this worse.

I'd like to express my objection to de-designation of Green Belt.
Brentwood can meet its own needs and much more without using Green Belt. The OAN goes far beyond that and the Council should therefore use Green Belt and transport constraints as a reason not to meet OAN.
I draw your attention to the study by the SE Essex Action Group Alliance into the overstretched C2C line, the limited potential for improvements and the huge demand growth projections.
The Study also has significant detail on the limitations of the Anglia route but focusses on the Southend Victoria branch.
Executive Summary: http://seeaga.uk/SEEAGA%20-%20Rail%20Topic%20Paper%20-%20Exec%20Summary%20v1.pdf
1. Executive Summary - seeaga.uk
seeaga.uk
SE Essex Action Group Alliance - 2017 1 1. Executive Summary One of the original reasons for establishing the Green Belt around London was to prevent the capital's
Full Paper: http://seeaga.uk/SEEAGA%20-%20Rail%20Topic%20Paper%20v1.pdf
Two Birds in the Hand Topic Paper on SE Essex' commuter ...
seeaga.uk
SE Essex Action Group Alliance - 2017 1 Two Birds in the Hand Topic Paper on SE Essex' commuter rail links SE Essex Action Group Alliance

1. The building of unaffordable houses for people and destroying Greenbelt for monetary gain for the developers is unacceptable & immoral. The LDP shows land miss represented as Brownfield when it is most certainly Greenbelt in the current house market, householder need to upgrade by 200,000 pounds at least, this housing is not affordable for our younger generations

2. Our precious greenbelt provides fresh air alleviating pollution from east the A127, as records show the A127 is exceeding levels of pollution & there is now talk of emission charge ! The woodland & Greenbelt are needed to counteract these pollution levels.

3. These areas have inhabitants of precious Wildlife & will be adversely affected & lost forever -sites of SSI are in place for a reason as is protected Greenbelt -this can not be the allocated

4.All of our facilities are stretched -overburdened roads , GP surgeries ,schools , hospitals -A127 , A128 & Billericay roads are at a standstill certain times of the day -roads are at breaking point . There is no infrastructure for these said unaffordable
Houses. The area is highly congested already causing pollution

5.The figures are completely manipulated why If this is a local plan it is common knowledge that the homes are for executive for those coming from outside if the area .

6.the actual numbers of houses needed is not quantifiable not necessary or needed with the EU brexit we have no idea how many people will be here after these figures you have grabbed we're prior to the referendum last year

I strongly object to all of your planning proposals to build on 2005 designated Greenbelt for a number of reasons.

Our precious greenbelt provides fresh air alleviating pollution from east the A127, as records show the A127 is exceeding levels of pollution & there is now talk of emission charge ! The woodland & Greenbelt are needed to counteract these pollution levels.

These areas have inhabitants of precious Wildlife & will be adversely affected & lost forever -sites of SSI are in place for a reason as is protected Greenbelt -this can not be the allocated

All of our facilities are stretched -overburdened roads , GP surgeries ,schools , hospitals -A127 , A128 & Billericay roads are at a standstill certain times of the day -roads are at breaking point . There is no infrastructure for these said unaffordable
Houses. The area is highly congested already causing pollution


Actual numbers of houses needed is not quantifiable not necessary or needed with the EU brexit we have no idea how many people will be here after these figures you have grabbed we're prior to the referendum last year.

To whom it may concern
I object to this consultation as it is flawed figures are incorrect & Greenbelt is misrepresented on your plans I am looking to buy a house in the area I was brought up , this will be unaffordable for me .
The houses are for people coming in fro
Outside of the area NOT for local people like me -I am out priced from living i this area .
Greenbelt should never be built on for monetary gain for developers .
Our roads are overburdened it takes my over half an hour to get to West Horndon station from Billericay Rd !
Greenbelt & wildlife should be protected -Brown field used first .

I object to this consultation as it is flawed figures are incorrect & Greenbelt is misrepresented on your plans I am looking to buy a house in the area I was brought up , this will be unaffordable for me .
The houses are for people coming in fro
Outside of the area NOT for local people like me -I am out priced from living i this area .
Greenbelt should never be built on for monetary gain for developers .
Our roads are overburdened it takes my over half an hour to get to West Horndon station from Billericay Rd !

Thank you for your letter of 2nd inst. I have read the documents on the site and appreciate all the hard work, enquiries, projections, data analysis etc has led to what would have been a definitive work on Brentwood 2013-2033 but find there is a major flaw . The decision of the UK to leave the EU ( 2016 referendum ) will result in a major impact on any plans made by HMG or statutory authorities in relation to the economy, citizens and indeed land. I cannot see in any publication this major factor being taken into account. Surely even an addendum should be issued to highlight the effect of the decision taken in 2016.

The consultation document proposes a large number of possible sites for the development of residential and business properties. The supporting evidence on critical strategic infrastructure is poor; indeed they are described as "interim" and leave many issues not assessed. Of these the flood risk assessment for the area of West Horndon is a key missing assessment. West Horndon is recovered fen land and as such has poor natural drainage which was made much worse when in the 1800s the railway line was constructed. Subsequent industrial and residential development has only made matters even worse. Over many years there have been a number of significant incidents with properties being seriously flooded. Following floods in the early 1980s surface water drainage was improved but the risk is still significant and during the winters of both 2012 and 2013 properties were once again flooded. The NPPF is very clear (paragraphs 94 & 100 - 103) that any development must take full account of flood risk before development is considered. Given the lack of detailed flood risk assessment it is impossible for anyone to come to a view on the use of any of the sites in the West Horndon area because they cannot understand the flood risk. Thus, I question if this consultation is valid given the public are being asked to comment on something that no one can take an informed view of because of the lack of supporting evidence. The spatial strategy identifies the A127 corridor as an appropriate location for the development of new homes and business and employment opportunities. At first sight this is a reasonable approach, however there is no supporting evidence that infrastructure in the corridor could cope with the additional load such development would create. Currently the A127 is at or over capacity much of the time as is the C2C railway line. Given that other local authorities are proposing development that would need to be supported by the transport infrastructure of the A127 corridor there is no clear evidence that it will be possible to upgrade the current road and rail systems to cope with the additional housing/business development being proposed in this consultation document. I should point out that the rail line is only two tracks and Fenchurch Street station only has 4 platforms. It is hard to conceive that a significant increase in capacity can be created as there is no physical room for more platforms at Fenchurch Street and the line west of Upminster runs through dense residential development and thus the opportunity for upgrade must be minimal. Similarly, the A127 (which is only two lanes in each direction) west of Upminster also runs through residential areas thus increasing the number of lanes to increase capacity must be questionable. While I recognise the upgrade of strategic transport infrastructure is not within the remit of BBC, developing a Local Development Plan (LDP) in the absence of information about the critical infrastructure is a nonsense. The LDP should make it clear that any proposal is totally dependent on appropriate infrastructure upgrades being planned and implemented concurrently with the proposed development. I also point out that the trains from Brentwood and Shenfield are on the new Cross-Rail line and thus the capacity is significantly improved. There are plans to upgrade much of the A12 to three lanes in each direction - so with respect to transport infrastructure corridors it is the A12 corridor that would seem most appropriate to consider for residential and business development opportunities than the A127 corridor. This site, south of the Grade 2 listed East Horndon Hall is being proposed for development as an industrial site. This land is Green Belt and thus any development is inappropriate. The NPPF clearly states that for development to take place in the Green Belt very exceptional circumstances need to be demonstrated. None are. This land is also subject to flooding - it regularly has standing surface water and acts as a storage buffer which prevents flooding of the surrounding land including residential areas. The planning application 17/01597/EIASO which first proposed this site for development as a business park includes a surface water flood assessment which only looks at a superficial level at the site itself. This is contrary to the NPPF (paragraph 102) which requires a flood risk assessment that demonstrates that any such development does not increase flood risk elsewhere. Given the history of flooding in this area (properties were flooded, and the main road blocked in December 2012) this site is clearly inappropriate for any development. These now aging industrial sites are appropriate for redevelopment and redevelopment to residential (or part residential) use is appropriate for this brown field land. In broad outline I support these sites being redeveloped. However, there are a number of concerns that must be taken into account. 1. Access - the current access arrangement date back to the late 1930s when the site was first built. The amount of traffic in those days was significantly lower than today. The current land use means that much of the traffic is large HGV lorries which are large and easy to see. Redevelopment to mixed residential and business use will increase the number of cars and light van traffic which will increase the risk of accidents. There already a large number of small shunt accidents in the vicinity of the entrance to this site. Thus, it is imperative that before any redevelopment takes place vehicle and pedestrian access is properly resolved; 2. West Horndon is a rural community and the development must be sympathetic to this. This site is quoted as being 17.06ha. Given that rural residential development should be at about 30 properties per hectare the 580 quoted seems to be very much at the top end of the appropriate number; 3. Although West Horndon is identified as a transport hub on account of the Railway Station, access is only east/west so most residents will definitely need cars. It is imperative that the design of the site is such that car parking is at a higher level than is normal for transport hub locations. West Horndon already has significant residential parking problems and this redevelopment must not make that worse. Thus, the design and number of properties must be able accommodate sufficient parking. Design is for the normal planning process, but I would suggest that for the strategic purposes of the LDP the number of properties should not exceed 500 - reduced as necessary according to how much of the site remains in business employment usage. Broadly I support the development of these sites for employment. They are situated close to the M25 as a major transport link and their use especially for enterprises which use large amounts of HGV traffic would be welcomed as that would reduce HGV traffic through residential areas like the village of West Horndon. There are potential issues about access to these sites for staff working there, there is at present no public transport access. This detail will need to be dealt with at the full planning application stage. This area is Green Belt and thus development seems inappropriate. However, I do recognise that Brentwood is ~89% greenbelt and that opportunities for non-green belt development are limited. Given the strategic housing allocation central Government is imposing on BBC this area probably needs to be considered as an option. I point out that green belt to the north of the Borough is open and that development in such areas could be undertaken to make an isolated village(s). The Dunton Hills site is almost the last green belt gap between Upminster (London) and Southend thus the development of this site would basically create continuous development between London and Southend. This would seem to be contrary to the principles set out in the NPPF. I also question the ability to construct sufficient transport infrastructure to support the development, but I can find no assessments examining this situation in appropriate detail. However, given the situation BBC finds its self in Dunton Hills Garden Village (DHGV) may be the least worst option to meet the strategic housing allocation. If this is to proceed it must be done in such a way that the impact on the surrounding area and communities is limited to a minimum. To this end the western side of the site needs to be restricted and turned into a buffer zone e.g. by creating a woodland. This would have the effect of visual separation between the two villages and would also mitigate some of the potential flood risk that the development would create. It would also make future attempts to expand the development and join the two villages much more difficult. This approach is consistent with the guidance in the NPPF for change of use of green belt land. I suggest that the site map is modified to make it clear that there must be a buffer zone between the DHGV and the A128. If this development does proceed it will generate traffic between it and the railway station in West Horndon. Parking is already a problem in the village of West Horndon and it is essential that means to minimise and manage this are sought and incorporated at the very outset of planning. The current plan suggest that the required G&T site are developed and located adjacent to new residential developments as they are constructed. My understanding from the results previous consultations is that G&T communities prefer sites to be away from business and residential areas. Indeed, one G&T site situated just north of the A127/A128 junction has to my knowledge not been used in over 30 years. I understand this is because it is too close to other developments. This aspect of the site plan allocation needs a total rethink.

Paragraphs 41-42:
I oppose the 36% upward adjustment to the housing target made on the grounds of "affordability". The lack of affordable housing is due to prices being inflated by an unholy alliance of banks, estate agents, and government subsidy (cf. "Help to Buy" schemes). Even in London and the "Home Counties", there are many empty dwellings. Councils and government should concentrate on bringing more of these empty dwellings into use (the ability to impose a higher rate of Council Tax on such dwellings is one welcome development), instead of destroying the green belt. Within Essex, Brentwood will always command a premium, owing to its excellent transport links (both road and rail, as acknowledged in paragraph 26), no matter how much the supply of housing and employment land is increased. As a 25-year-old, I wish to make it clear that I object in the strongest terms to attempts at justifying destruction of the green belt in the name of "young people".

Sites 010, 022, 023A, 023B, 027, 032, 034, 075B, 076, 077, 079A, 083, 085B, 087, 106, 128, 158, 194, 200, 235, 263, 276, 294:

I oppose any encroachment on the green belt. The National Planning Policy Framework makes clear that the "permanence" and "openness" of the green belt are vital facets of its integrity. Paragraphs 44 and 45 of the NPPF also make clear that Objectively Assessed Housing Need is not the only pertinent factor in determining housing targets, and the significant amount of green belt land in the borough would be sufficient justification to set housing targets at a lower level than that suggested by the Objectively Assessed Housing Need (Brentwood's green belt is, according to the council's own strategic growth options development plan, "the sixth highest in England by percentage of total area"). Moreover, it should be observed that developers are failing to implement planning permissions already obtained (cf. section on Historic Building Rates, as described by the Council in its responses to Sajid Javid). Until such permissions have been utilised, it is unacceptable to reward developers with more permissions.

In short, I call upon the Council to declare the green belt as an absolute constraint (cf. draft local plan in 2013), notwithstanding the alleged risk of being found "structurally unsound". It is my view that the Council is exaggerating such a risk: past comments by Eric Pickles, former MP for Brentwood & Ongar, who was the minister responsible for implementing major legislative changes in the so-called "localism agenda", have made clear that the green belt is a sound reason for reducing the housing targets.

Paragraph 63:

The Brentwood Town Centre Design Plan (2017) has some promising ideas. However, it could be more ambitious in the density proposed. Given the high demand for housing and the excellent transport connections in the town centre, there should be a presumption in favour of taller buildings (preserving the green belt is far more important than preserving the so-called "skyline"), provided that they do not impinge upon the "right to light" of existing dwellings and gardens.

Sites 002, 003, 039, 040, 041, 081, 102, 117A, 117B, 186:

In general, I support the development of these sites, provided that they are developed in a manner that does not necessitate significant felling of trees now or in the future. Woodland is of immense value aesthetically, recreationally, and environmentally. Brentwood benefits from having woodland within very easy reach, and it is vital that this remains the case, including in the urban parts not designated as "green belt".
As stated in my comment on paragraph 63, I believe that the density proposed for these sites could be higher. Higher densities on these brownfield sites would then obviate any alleged need to develop other sites.

Site 102:

I support an approach that prioritises the residential facet, maximising the number of dwellings, subject to respecting the "right to light" of adjacent properties. I believe that more than 300 residential dwellings could and should be built here. The need for more medium-sized commercial units (cf. Brentwood Town Centre Design Plan (2017)) can be realised through the repurposing/refurbishment of existing commercial buildings, including the Baytree Centre, which has never been at full occupation.

Sites 044 and 178:

Although not green belt, these sites offer open space within the urban area, and are thus of immense value in their present state. Furthermore, existing infrastructure is not amenable to development — public transport in the vicinity is almost non-existent, and the roads would struggle to accommodate the extra traffic.

Employment Sites 079C, 101A, 187, 200:

I oppose any encroachment on the green belt. The National Planning Policy Framework makes clear that the "permanence" and "openness" of the green belt are vital facets of its integrity.
The Council could consider larger allocations in the town centre, especially in underutilised retail areas such as the Baytree Centre.
I call upon the Council to declare the green belt as an absolute constraint (cf. draft local plan in 2013), notwithstanding the alleged risk of being found "structurally unsound". It is my view that the Council is exaggerating such a risk: past comments by Eric Pickles, former MP for Brentwood & Ongar, who was the minister responsible for implementing major legislative changes in the so-called "localism agenda", have made clear that the green belt is a sound reason for reducing targets.